The current regulations governing the practice of behavior analysis in the Commonwealth are sufficient. These emergency regulations, which were informed by the Behavior Analyst Certification Board's Guidelines for Responsibile Conduct for Behavior Analysts, have enabled thousands children and adolescents diagnosed with ASD across the Commonwealth to overcome the challenges associated with Autism Spectrum Disorders. The proposed changes to these regulations will negatively impact the current service delivery model and may leave thousands of children without appropriate and effective treatment.